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STURDZA: THE CLIENT’S SIDE To the editor: This letter is in reply to Nathan Lewin’s Feb. 10 letter [" Lewin on the Sturdza Litigation,"], which was a response to the Feb. 3 article on my case, Sturdza v. United Arab Emirates [" Drawing a Line," Feb. 3, 2003]. Prior to signing a retainer with Mr. Lewin, I gave him a written summary of facts and explained the damages caused by the defendants. Mr. Lewin promised to do everything the law permits. However, since his brief did plead for only one count (copyright infringement) out of nine, I asked him to: 1. Plead criminal copyright infringement due to the willfully planned copying, to support the tort claims wrongfully based only on the breach of contract. 2. Correct the pleading on Count 1, Breach of Contract; Count 2, Quantum Meruit; Count 5, Conspiracy to Commit Fraud; Count 6, Tortious Interference With Contract; and Count 7, Intentional Infliction of Emotional Distress, and — since no law, no one, and no contract asked for a D.C. license — withdraw the question designed to call for a D.C. license and cause the dismissal of all five counts. In fact, the U.S. Department of State, to encourage designs by foreign architects, replaced the D.C. Zoning Regulations and the requirement for D.C. license with the Development Controls for the size, location, and esthetics of new embassies at the International Center. Slovakian and Italian architects designed the Slovakian and the Italian embassies, and no D.C. license was required of them. No D.C. license was required for the UAE Chancery. 3. Plead for the abandoned Count 4, Conversion, and Count 8, D.C. Human Rights Act. 4. Plead correctly Count 9, Civil Rights, 42 U.S.C. �1985, add �1983,6, and later file a petition to the U.S. Supreme Court since it was dismissed under the wrong assumption of UAE immunity as a foreign state. 28 U.S.C. �1603,5,6 says that “a foreign government is not immune and is a person when engaged in a commercial activity and shall be liable in the same manner and to the same extent as a private individual.” 5. Mention that the District Court did not allow me to serve discovery requests while it forced me to produce everything the defendants asked for. 6. Explain that my previous lawyers promised to amend the complaint and add the UAE’s lawyers and representatives in the contract negotiations as defendants. Since the review was de novo on appeal, Mr. Lewin should have raised all the issues and counts dismissed in the lower court as promised initially. Since July 2001, I repeatedly asked Mr. Lewin to correct the brief or explain the reasons for his actions. When he refused, I filed motions requesting permission to correct the brief and the appendix. Mr. Lewin told the court that my citing of the applicable laws were “poor legal arguments” and that real facts were “unsubstantiated factual allegations.” On April 2, 2002, I wrote a letter asking him again to explain why he ignored my suggestions. He answered that he acted according to “his best professional judgment” and never explained what that judgment was based on. Mr. Lewin never mentioned to me that the defendants offered a settlement. He only suggested that they might. When it became clear to me that Mr. Lewin was acting against my interests, on May 23, 2002, I gave him an ultimatum: either answer my questions or I will take action. His answer was the filing of his Motion for Appointment of Guardian ad Litem. At this point in time, the only way to resolve this dispute is to make my case in front of a jury. It is my right under U.S. law. Elena Sturdza Elena Sturdza Architect Cabin John, Md.

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